Compliance Program, Referral Integrity and Fraud Prevention
Sets out the Agency's compliance program and the rules every employee, contractor and volunteer follows on referrals, gifts, marketing, eligibility, billing and conflicts of interest, under the federal fraud and abuse laws and the Pennsylvania Medical Assistance provider rules, and how anyone can raise a concern without retaliation.
About this policy
- Policy number
- PA-HSP-ETH-01
- Version
- 1.0
- Main rule
- 42 U.S.C. §1320a-7b(b)
- Library
- Pennsylvania hospice · 60 policies
- Category
- Ethics
- Sections
- 17
In short
- Never give or accept money, gifts or favors in return for patient referrals.
- Admit and keep only patients who are eligible for hospice. Never pressure a doctor or a family.
- Document only what you actually did, on time, and never sign for someone else.
- Do not give patients or families gifts or free items to choose the Agency.
- Report concerns to your manager or Pat Sample. You can report anonymously, and you will not be punished for reporting in good faith.
What's inside
17 sections. The full text comes with the One-time Policy Pack.
- Terms of Reference
- 1. Purpose
- 2. Scope
- 3. Definitions
- 4. Policy Statement (42 U.S.C. §1320a-7b(b))
- 5. Rules for Staff
- 6. Referral Relationships and Business Courtesies
- 7. Compliance Program
- 8. Reporting Concerns
- 9. Investigation and Corrective Action
- 10. Responsibilities
- 11. Records and Compliance Monitoring
- 12. Staff Training
- 13. References
- 14. Related Policies and Forms
- 15. Approval
- 16. Revision History
An inspector may ask
- Do you give anything of value to referral sources or nursing facilities?
- How do staff report a compliance concern, and how are they protected?
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